For the second time, a scheme involving borrowings in Turkish lira to generate tax-deductible interest has come before the Tax Appeals Commission. As reported last year, a group of 35 investors had previously challenged a Revenue decision to refuse them tax relief on the cost of their €40 million Turkish-denominated loans. At the time, the appeal body had ruled that the choice of the exotic, high-interest-rate currency to conduct an arcane debt deal across multiple borders had no other purpose than to manufacture tax deductions, and sided with the tax authority. This time, the facts of the case are slightly…
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